He was speaking at the Futures Industry Association conference in Boca Raton, Florida, via a live broadcast from the CFTC offices.

Implementing the Act has become a fraught issue because it makes great demands on regulators, including the CFTC and Securities and Exchange Commission, to formulate rules. These have to go through laborious analysis and public comment procedures, and the regulators have so far not been given any budget increase to cope with their new responsibilities.

Republican opponents of Dodd-Frank are using budget pressure as a lever to impede the Act’s implementation.

Gensler said that while the three phases were not finalised and were still subject to change, they were the best gauge of how the new rules would be implemented.

The first or early phase, this spring, is likely to include rules to define entities and set registration requirements for two new regulatory categories: swap dealers and major swap participants.

Also likely to be implemented by the end of spring – in other words, by June – said Gensler, was the rule giving ‘end users’ an exception from clearing requirements.

In this phase, too, are process rules to govern mandatory clearing; rule submissions from clearing houses and exchanges; the large trader reporting rule; and enforcement rules such as fair credit reporting, consumer information privacy and conflicts of interest.

The second group of rules will be rolled out during the summer months. This will likely include a rule related to the controversial topic of position limits, as well as rules related to clearing houses; business conduct; swap data repositories and their reporting requirements; and trading markets.

The trading markets heading includes regulations for trading platforms such as designated contract markets (DCMs), swap execution facilities (SEFs), and foreign boards of trade, and real time reporting and block trading rules.

The last phase of rulemaking, due in later summer and early autumn, will probably include rules relating to disruptive trading practices, interpretative orders, product definitions, capital and margin requirements, supervision and testing requirements and conforming rules.